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61 documents · 0.22sAllIRCERISAPBGCJoint Board
  1. T.C. Summary Opinion 2008-1 — Shawn Timothy Hynes v. Commissioner
    IRCCourt RulingsJan 2, 2008related by meaning
    oner . Sec . 7491(a)(1) ; Rule 142(a)(2) . Petitioner did not argue that section 7491 is applicable, and he did not establish that the burden of proof should shift to respondent . Petitioner, therefore, bears the burden of proving that respondent's determination in the notice of deficiency is erroneous . See Rule 142(a…